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3.  Defendant denies paragraphs 6 to 25 of the
                    witness statement and Claimant is put to proof.
                 4.  Paragraph 27 of the witness statement is
                    denied. Defendant avers that he has always
                    granted access to the Claimant and its
                    contractors upon being given reasonable
                    notice.
                 5.  Defendant denies paragraphs 28 to 33 of the
                    witness statement and the Claimant is put to
                    strict proof
                 6.  Defendant avers that he suffers from mental
                    health problems and is under the care of the
                    mental health team which the Claimant has
                    always been aware of and in breach of its duty
                    under section 15 and 149 of the Equality Act
                    2010. Defendant has on several occasions
                    complained to the Claimant about noise and
                    other antisocial behaviour by the tenants of
                    113 and 117 but Claimant
               305
               8 August 2017
               Dated: 22/09/2017
                    failed or refused to investigate and/or take any
                    action which there was no possible reason
                    other than the Defendant's mental health
                    problems.
                 7.  The Defendant respectfully requests the court
                    to discharge the injunction dated 8 August
                    2017.
                 Statement of Truth
                 Defendant believes the facts stated in this Defence
                 are true. I am authorised by the Defendant to sign
                 this statement.
                 Signed: “Yes”
                 Name: Emanuel Onwusim
                 Dated: 22/09/2017
                 VLS Solicitors
                 Gibson House
                 800 High Road Tottenham
                 London
                 N17 0DH
                 Ref: VLS/EO/H/CORDELL/17

               306

                         CLAIM NUMBER: D02EDO73

                   IN THE EDMONTON COUNTY COURT

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